From: cdpaulick@worldnet.att.net
Sent: Saturday, November 02, 2002 6:28 AM
To: rule-comments@sec.gov
Subject: File No. S7-36-02
Dear SEC Secretary,
I am writing in support of the SEC's proposed rule to require mutual fund
companies to disclose how they vote on corporate proxy resolutions, which
often deal with issues of concern to me. The recent wave of corporate
scandals provides ample evidence that corporate America need greater transparency,
responsibility and accountability. It is estimated that mutual funds, which
represent about 90 million Americans, account for 20 percent of proxy votes at
corporate shareholder meetings. As such, mutual funds can play a major role in
insisting on more responsible behavior on the part of publicly traded companies.
In the absence of public disclosure of proxy policies and proxy voting records,
there is no way for me to know whether the manager of my mutual fund is acting
in a manner that reflects my wishes. As a mutual fund shareholder, I want to
know how my mutual fund is voting on issues related to executive pay, board make-up
and independence, global warming and other environmental issues, worker rights,
gender discrimination and other issues that matter to me. I want potential
conflicts of interest exposed. I want to know what principles will guide the
mutual fund in determining how it votes in corporate proxy contests.
I believe that as an owner of a mutual fund, I am entitled to know how my proxy
is being voted. I urge the SEC to stand up for investors and for corporate
accountability and to vote in favor of the proposed proxy voting rule.
Letting the Mutual Fund companies keep their proxy voting habits, on corporations
they represent, a secret from the investors is like "letting the Fox (the Mutual
Fund Companies) guard the Hen-House (fee-paying corporations) and not telling the
Roosters (Small investors)how the hens are selected for breeding and/or butchering
(proxy votes were cast)."
Du Wayne F. Paulick
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Rochest er, New York
14606